Judge tears apart Trump lawyer for using fake AI citation

U.S. President Donald Trump reacts as he speaks during the signing ceremony for an executive order on mail ballots, in the Oval Office of the White House in Washington, D.C., March 31, 2026. REUTERS Evan Vucci

Lawyers arguing on behalf of the Trump administration appear to have used a fake, AI-generated citation, prompting a bench-slap from the judge.

“The Justice Department appears to have included a fake AI-generated citation in an ICE detainee's case, “ Politico Senior Political Affairs Correspondent Kyle Cheney posted on Thursday. “Judge Jarbou, a Trump appointee in Michigan, called it out.”

Cheney attached screenshots of a ruling by Judge Hala Jarbou, who was appointed by President Donald Trump in March 2020. The first read, “The cited case, Taylor v. Hott, is not located at the identified page of the Federal Appendix. Indeed, page 387 is contained within two different opinions–—Atkins v. CGI Techs. & Sols., Inc., 724 F. App’x 383 (6th Cir. 2018)—which is about commercial arbitration, not immigration bond determinations. In its research, the Court was unable to identify a Sixth Circuit case with the caption Taylor v. Hott, or any federal case containing the quoted language. Thus, it seems this citation was likely produced by generative artificial intelligence (‘AI’).”

A second screenshot continues, “It should be obvious that any attorney who uses AI must scrupulously review its work product to ensure that the cited cases exist and that the citations accurately and fairly represent the underlying case law. The duty of candor towards this tribunal demands no less.”

The judge was lenient on the attorney, writing, “Although the Court will not presently impose sanctions for this conduct, it goes without saying that the Government must ensure its future filings with this Court do not include non-existent case law.”

Reactions have been wide ranging, but Bulwark editor Sam Stein summed it up in a word: “Embarrassing.”

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